SOUTH WAIKATO DISTRICT COUNCIL AND GENESIS ENERGY - Electricity Authority
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ELECTRICITY INDUSTRY PARTICIPATION CODE
DISTRIBUTED UNMETERED LOAD AUDIT REPORT
VERITEK
For
SOUTH WAIKATO DISTRICT COUNCIL AND
GENESIS ENERGY
Prepared by: Rebecca Elliot
Date audit commenced: 21 March 2018
Date audit report completed: 28 May 2018
Audit report due date: 01-Jun-18
1TABLE OF CONTENTS
Executive summary ....................................................................................................................................... 3
Audit summary .............................................................................................................................................. 4
Non-compliances ................................................................................................................................ 4
Recommendations .............................................................................................................................. 4
Issues 4
1. Administrative ..................................................................................................................................... 5
Exemptions from Obligations to Comply with Code ................................................................. 5
Structure of Organisation .......................................................................................................... 5
Persons involved in this audit.................................................................................................... 5
Hardware and Software ............................................................................................................ 6
Breaches or Breach Allegations ................................................................................................. 6
ICP Data ..................................................................................................................................... 6
Authorisation Received ............................................................................................................. 6
Scope of Audit ........................................................................................................................... 6
Summary of previous audit ....................................................................................................... 7
Distributed unmetered load audits (Clause 16A.26 and 17.295F) ............................................ 8
2. DUML database requirements ............................................................................................................ 9
Deriving submission information (Clause 11(1) of Schedule 15.3) ........................................... 9
ICP identifier and items of load (Clause 11(2)(a) and (aa) of Schedule 15.3) .........................10
Location of each item of load (Clause 11(2)(b) of Schedule 15.3) ..........................................11
Description and capacity of load (Clause 11(2)(c) and (d) of Schedule 15.3) .........................11
All load recorded in database (Clause 11(2A) of Schedule 15.3) ............................................11
Tracking of load changes (Clause 11(3) of Schedule 15.3) ......................................................13
Audit trail (Clause 11(4) of Schedule 15.3) ..............................................................................14
3. Accuracy of DUML database .............................................................................................................15
Database accuracy (Clause 15.2 and 15.37B(b)) .....................................................................15
Volume information accuracy (Clause 15.2 and 15.37B(c)) ....................................................16
Conclusion ...................................................................................................................................................18
Participant response .........................................................................................................................19
2EXECUTIVE SUMMARY
This audit of the South Waikato District Council Unmetered Streetlights (SWDC) DUML database and
processes was conducted at the request of Genesis Energy Limited (Genesis), in accordance with clause
15.37B. The purpose of this audit is to verify that the volume information is being calculated accurately,
and that profiles have been correctly applied.
The audit was conducted in accordance with the audit guidelines for DUML audits version 1.1, which
became effective on 1 June 2017.
Odyssey Energy (2009) Limited (Odyssey) manages the installation, maintenance and database
management of all SWDC lighting connections.
SWDC are installing a CMS system and metering this DUML load, therefore this will no longer require an
audit as a DUML load which is expected to be by the end of August.
The database contains a small number of ballast discrepancies. These are discussed in the report.
The audit found three non-compliance issues and makes no recommendations. The future risk rating of
six indicates that the next audit be completed in 24 months. The matters raised are detailed below:
3AUDIT SUMMARY
NON-COMPLIANCES
Subject Section Clause Non-Compliance Controls Audit Breach Remedial
Risk Risk Action
Rating Rating
Deriving 2.1 11(1) of The database accuracy is Moderate Low 2 Identified
submission Schedule assessed to be 99.6%
information 15.3 indicating an estimated
minor over submission of
450 kWh per annum.
Database 3.1 15.2 and The database accuracy is Moderate Low 2 Identified
accuracy 15.37B(b) assessed to be 99.6%
indicating an estimated
minor over submission of
450 kWh per annum.
Volume 3.2 15.2 and The database accuracy is Moderate Low 2 Identified
information 15.37B(c) assessed to be 99.6%
accuracy indicating an estimated
minor over submission of
450 kWh per annum.
Future Risk Rating 6
Future risk 1-3 4-6 7-8 9-17 18-26 27+
rating
Indicative audit 36 months 24 months 18 months 12 months 6 months 3 months
frequency
RECOMMENDATIONS
Subject Section Description Action
Nil
ISSUES
Subject Section Description Issue
Nil
41. ADMINISTRATIVE
Exemptions from Obligations to Comply with Code
Code reference
Section 11 of Electricity Industry Act 2010.
Code related audit information
Section 11 of the Electricity Industry Act provides for the Electricity Authority to exempt any participant
from compliance with all or any of the clauses.
Audit observation
Section 11 of the Electricity Industry Act provides for the Electricity Authority to exempt any participant
from compliance with all or any of the clauses.
Audit commentary
Genesis confirms that there are no exemptions in place relevant to the scope of this audit.
Structure of Organisation
Genesis provided the relevant organisational structure:
Persons involved in this audit
Auditor:
Rebecca Elliot
Veritek Limited
Electricity Authority Approved Auditor
Other personnel assisting in this audit were:
Name Title Company
Craig Young Excellence Leader- Reconciliation Genesis Energy
David Raven Street light Consultant Odyssey
5Hardware and Software
Section 1.8 Section 1.2 shows that the SQL database used for the management of DUML is remotely
hosted by RAMM Software Ltd. The database is commonly known as “RAMM” which stands for “Roading
Asset and Maintenance Management”. The specific module used for DUML is called RAMM Contractor.
Database back-up is in accordance with standard industry procedures. Access to the database is secure
by way of password protection.
Breaches or Breach Allegations
There are no breach allegations relevant to the scope of this audit.
ICP Data
ICP Number Description NSP Profile Number Database wattage
of items (watts)
of load
1000499769PCCB7 SOUTH WAIKATO HIN0331 NST 897 104,281
STREETLIGHTS,
STREETLIGHTS,
WAIKATO 2392
1000571665PC2BC South Waikato KIN0331 NST 1,673 176,616
District Council
Streetlights
0000036463HR791 STREETLIGHTING, ROT0111 NST 17 3,736
STATE HIGHWAY 1,
ATIAMURI, BAY OF
PLENTY
Authorisation Received
All information was provided directly by Genesis or Odyssey.
Scope of Audit
This audit of the South Waikato District Council Unmetered Streetlights (SWDC) DUML database and
processes was conducted at the request of Genesis Energy Limited (Genesis), in accordance with clause
15.37B. The purpose of this audit is to verify that the volume information is being calculated accurately,
and that profiles have been correctly applied.
The audit was conducted in accordance with the audit guidelines for DUML audits version 1.1, which
became effective on 1 June 2017.
The database is remotely hosted by RAMM Software Ltd and is managed by Odyssey, on behalf of SWDC,
who is Genesis’s customer. McKay Electrical, who is a contractor to Odyssey, and is engaged by SWDC,
conducts the fieldwork and asset data capture. Reporting is provided to Genesis on a monthly basis by
Odyssey.
The scope of the audit encompasses the collection, security and accuracy of the data, including the
preparation of submission information based on the database reporting. The diagram below shows the
audit boundary for clarity.
6McKay Electrical
Genesis Energy
Field work and asset data
capture
Preparation of submission Reconciliation
information Manager
Wattage report
RAMM Software Ltd Odyssey Energy Data Logger
(on/off times)
Auckland
RAMM database Database Database
management reporting
Audit Boundary
The field audit was undertaken of a statistical sample of 257 items of load on 19th March 2018.
Summary of previous audit
Genesis provided a copy of the last audit report undertaken by Steve Woods of Veritek Limited in May
2017 this audit report was undertaken for Genesis as part of their 2017 reconciliation participant audit.
This audit wasn’t submitted due to the audit regime change that occurred on 1st June 2017. For
completeness I have included the findings for reference below:
Table of Non-Compliance
Subject Section Clause Non-compliance Status
ICP identifier 2.2.1 11(2)(a) At least one additional ICP required on the Powerco Cleared
of network.
schedule
15.3
Table of Recommendations
Subject Section Clause Recommendation for Improvement Status
Nil
7Distributed unmetered load audits (Clause 16A.26 and 17.295F)
Code reference
Clause 16A.26 and 17.295F
Code related audit information
Retailers must ensure that DUML database audits are completed:
1. by 1 June 2018 (for DUML that existed prior to 1 June 2017)
2. within three months of submission to the reconciliation manager (for new DUML)
3. within the timeframe specified by the Authority for DUML that has been audited since 1 June
2017.
Audit observation
Genesis have requested Veritek to undertake this streetlight audit.
Audit commentary
This audit report confirms that the requirement to conduct an audit has been met for this database
within the required timeframe. Compliance is confirmed
82. DUML DATABASE REQUIREMENTS
Deriving submission information (Clause 11(1) of Schedule 15.3)
Code reference
Clause 11(1) of Schedule 15.3
Code related audit information
The retailer must ensure the:
• DUML database is up to date
• methodology for deriving submission information complies with Schedule 15.5.
Audit observation
The process for calculation of consumption was examined and the application of profiles was checked.
The database was checked for accuracy.
Audit commentary
Genesis reconciles this DUML load using the NST profile. The total volume submitted to the Reconciliation
Manager is based on a monthly database report from RAMM and the “burn time” which is sourced from
a data logger installed on the Powerco network for two of the three ICPs. I checked the methodology
used and confirm compliance for these ICPs. The volumes of lights recorded in the monthly wattage
report were greater than the volume provided in the monthly report. This suggests that the database
extract provided was incomplete and therefore I have not recorded this variance as over submission. In
addition to this, the load is being metered in the near future. The registry data is used for ICP
0000036463HR791. The kW value matches that recorded in the database and the methodology was
confirmed to be compliant.
There are a small number of inaccurate ballasts being applied within the database used to calculate
submissions. This is recorded as non-compliance and discussed in sections 3.1 and 3.2.
Audit outcome
Non-compliant
9Non-compliance Description
Audit Ref: 2.1 The database accuracy is assessed to be 99.6% indicating an estimated minor over
submission of 450 kWh per annum.
With: Clause 11(1) of
Schedule 15.3 Potential impact: Low
Actual impact: Low
Audit history: Twice
From: 01-Jun-17 Controls: Moderate
To: 30-Apr-18 Breach risk rating: 2
Audit risk rating Rationale for audit risk rating
Low The controls are rated as moderate, because they are sufficient to ensure that lamp
information is correctly recorded most of the time.
The impact is assessed to be low, based on the kWh differences described above.
Actions taken to resolve the issue Completion Remedial action status
date
Genesis have been working with SWDC to maintain their 10/2018 Identified
database. Actions are to introduce led (smart city) infrastructure
with a CMS system overlaying measuring usage. Genesis have
request AMS metering to be post CMS to capture volumes for
billing and settlement.
Preventative actions taken to ensure no further issues will occur Completion
date
Genesis has requested meters which will remove the need for 10/2018
DUML databases.
ICP identifier and items of load (Clause 11(2)(a) and (aa) of Schedule 15.3)
Code reference
Clause 11(2)(a) and (aa) of Schedule 15.3
Code related audit information
The DUML database must contain:
• each ICP identifier for which the retailer is responsible for the DUML
• the items of load associated with the ICP identifier.
Audit observation
The database was checked to confirm the correct ICP was recorded against each item of load.
Audit commentary
The RAMM database contains the relevant ICP identifiers for all items of load.
Audit outcome
Compliant
10Location of each item of load (Clause 11(2)(b) of Schedule 15.3)
Code reference
Clause 11(2)(b) of Schedule 15.3
Code related audit information
The DUML database must contain the location of each DUML item.
Audit observation
The database was checked to confirm the location is recorded for all items of load.
Audit commentary
The database contains the nearest street address, pole numbers and Global Positioning System (GPS)
coordinates for each item of load, and users in the office and field can view these locations on a
mapping system.
Audit outcome
Compliant
Description and capacity of load (Clause 11(2)(c) and (d) of Schedule 15.3)
Code reference
Clause 11(2)(c) and (d) of Schedule 15.3
Code related audit information
The DUML database must contain:
• a description of load type for each item of load and any assumptions regarding the capacity
• the capacity of each item in watts.
Audit observation
The database was checked to confirm that it contained a field for lamp type and wattage capacity and
included any ballast or gear wattage and that each item of load had a value recorded in these fields.
Audit commentary
The database contains two records for wattage, firstly the lamp wattage and secondly the gear wattage,
which represents ballast losses. The gear wattage is recorded in the database which meets the
requirements of this clause. I found no blank records. The accuracy of the description and wattages
recorded is discussed in section 3.1.
Audit outcome
Compliant
All load recorded in database (Clause 11(2A) of Schedule 15.3)
Code reference
Clause 11(2A) of Schedule 15.3
Code related audit information
The retailer must ensure that each item of DUML for which it is responsible is recorded in this database.
11Audit observation
The field audit was undertaken of a statistical sample of 257 items of load on 19th March 2018.
Audit commentary
The field audit findings are detailed in the table below:
Street Database Field Light count Wattage Comments
count count differences recorded
incorrectly
Large Town
ANNE ST 3 3
BORONIA ST 8 8
BRIDGE ST 9 9
BRIDGE ST (NORTH) 12 12
CENTRAL
CURRIE ST 3 3
DUNKELD PL 6 6
GIRVAN PL 4 4
HAWICK ST 7 7
HINAU ST 3 3
MATIPO PL 3 3
MAYFAIR PL 2 2
MORVERN CRES 16 16
O'SULLIVAN DR(SOUTH) 6 6
PAPANUI ST (NORTH) 16 16
PARAONUI RD 19 19
PORRITT PL 2 2
PRINCESS BEATRIX AVE 12 12
ROSLIN ST (SOUTH) 9 9
SWANSTON ST 10 10 1 1x LED found in the field
recorded as MH in the database
12WEKA PL (A) 1 1
Main Roads 35 35
ARAPUNI 21 21
HUIHUITAHA 2 2
OVERDALE 8 8
SH 27 3 3
WILTSDOWN EAST 1 1
Small town
ARAPUNI 18 18
COUNTY PL 4 4
HIGH ST (TIRAU) 4 4
JORDAN PL 1 1
ROSE ST 6 6
SEALY CRES 3 3
Grand Total 257 257 Nil 1
I found no lamp count errors. One lamp wattage difference was found in the field. This is discussed in
section 3.1.
Audit outcome
Compliant
Tracking of load changes (Clause 11(3) of Schedule 15.3)
Code reference
Clause 11(3) of Schedule 15.3
Code related audit information
The DUML database must track additions and removals in a manner that allows the total load (in kW) to
be retrospectively derived for any given day.
Audit observation
The process for tracking of changes in the database was examined.
Audit commentary
Any changes that are made during any given month take effect from the beginning of that month. The
information is available which would allow for the total load in kW to be retrospectively derived for any
day. On 20th September 2012, the Authority sent a memo to Retailers and auditors advising that
tracking of load changes at a daily level was not required as long as the database contained an audit
13trail. I have interpreted this to mean that the production of a monthly “snapshot” report is sufficient to
achieve compliance.
The processes were reviewed for ensuring that changes in the field are notified through to Odyssey.
McKay Electrical enters all field data via “Pocket RAMM” directly into RAMM Contractor. Monthly “outage
patrols” are conducted, and this process is used to check database accuracy. All McKay Electrical invoices
are checked by Odyssey to ensure there is a match between database information and invoice
information.
Outage patrols will be in place until SWDC’s CMS is in place and the streetlights are metered. This consists
of a monthly night time patrol of the network and a six-monthly patrol to pick up any other issues that
can’t be seen during the night patrols.
There have been no new developments since the last audit and going forward all new streetlights will be
connected to metered circuits.
Audit outcome
Compliant
Audit trail (Clause 11(4) of Schedule 15.3)
Code reference
Clause 11(4) of Schedule 15.3
Code related audit information
The DUML database must incorporate an audit trail of all additions and changes that identify:
• the before and after values for changes
• the date and time of the change or addition
• the person who made the addition or change to the database.
Audit observation
The database was checked for audit trails.
Audit commentary
The RAMM database has a complete audit trail of all additions and changes to the database information.
Audit outcome
Compliant
143. ACCURACY OF DUML DATABASE
Database accuracy (Clause 15.2 and 15.37B(b))
Code reference
Clause 15.2 and 15.37B(b)
Code related audit information
Audit must verify that the information recorded in the retailer's DUML database is complete and
accurate.
Audit observation
The DUML Statistical Sampling Guideline was used to determine the database accuracy. The table below
shows the survey plan.
Plan Item Comments
Area of interest South Waikato area
Strata The database contains items of load in South
Waikato District Council area.
The council area covers two different networks of
Powerco and a small number of lights on the
Unison network.
The processes for the management of are the
same across the district but I decided to place the
items of load into two strata, as follows:
1. Large towns
2. Small towns.
Area units I created a pivot table of the roads in each area
and I used a random number generator in a
spreadsheet to select a total of 31 sub-units.
Total items of load 257 items of load were checked.
Wattages were checked for alignment with the published standardised wattage table produced by the
Electricity Authority.
Audit commentary
The field data was 99.6% of the database data for the sample checked. The total wattage recorded in the
database for the sample was 20,617 watts. The estimated total wattage found in the field for the sample
checked was 20,552 watts, a difference of 65 watts. This will result in an estimated minor over submission
of 450 kWh per annum (based on annual burn hours of 4,271 as detailed in the DUML database auditing
tool).
The database was checked and found all ballasts were applied correctly.
Audit outcome
Non-compliant
15Non-compliance Description
Audit Ref: 3.1 The database accuracy is assessed to be 99.6% indicating an estimated minor over
submission of 450 kWh per annum.
With: Clause 15.2 and
15.37B(b) Potential impact: Low
Actual impact: Low
Audit history: None
From: 01-Jun-17 Controls: Moderate
To: 30-Apr-18 Breach risk rating: 2
Audit risk rating Rationale for audit risk rating
Low The controls are rated as moderate, because they are sufficient to ensure that lamp
information is correctly recorded most of the time.
The impact is assessed to be low, based on the kWh differences described above.
Actions taken to resolve the issue Completion Remedial action status
date
Genesis have been working with SWDC to maintain their 10/2018 Identified
database. Actions are to introduce led (smart city) infrastructure
with a CMS system overlaying measuring usage. Genesis have
request AMS metering to be post CMS to capture volumes for
billing and settlement.
Preventative actions taken to ensure no further issues will occur Completion
date
Genesis has requested meters which will remove the need for 10/2018
DUML databases.
Volume information accuracy (Clause 15.2 and 15.37B(c))
Code reference
Clause 15.2 and 15.37B(c)
Code related audit information
The audit must verify that:
• volume information for the DUML is being calculated accurately
• profiles for DUML have been correctly applied.
Audit observation
The submission was checked for accuracy for the month the database extract was supplied. This included:
• checking the registry to confirm that the ICP has the correct profile and submission flag
• checking the database extract combined with the burn hours against the submitted figure to
confirm accuracy.
16Audit commentary
Genesis reconciles this DUML load using the NST profile. The total volume submitted to the Reconciliation
Manager is based on a monthly database report from RAMM and the “burn time” which is sourced from
a data logger installed on the Powerco network for two of the three ICPs. I checked the methodology
used and confirm compliance for these ICPs. The volumes of lights recorded in the monthly wattage
report were greater than the volume provided in the monthly report. This suggests that the database
extract provided was incomplete and therefore I have not recorded this variance as over submission. In
addition to this, the load is being metered in the near future. The registry data is used for ICP
0000036463HR791. The kW value matches that recorded in the database and the methodology was
confirmed to be compliant.
The DUML database auditing tool provided a result indicating the field data was 99.6% of the database
data. This will result in an estimated minor over under submission by 450 kWh per annum.
Audit outcome
Non-compliant
Non-compliance Description
Audit Ref: 3.2 The database accuracy is assessed to be 99.6% indicating an estimated minor over
submission of 450 kWh per annum.
With: Clause 15.2 and
15.37B(c) Potential impact: Low
Actual impact: Low
Audit history: Twice
From: 01-Jun-17 Controls: Moderate
To: 30-Apr-18 Breach risk rating: 2
Audit risk rating Rationale for audit risk rating
Low The controls are rated as moderate, because they are sufficient to ensure that lamp
information is correctly recorded most of the time.
The impact is assessed to be medium, based on the kWh differences described
above.
Actions taken to resolve the issue Completion Remedial action status
date
Genesis have been working with SWDC to maintain their 10/2018 Identified
database. Actions are to introduce led (smart city) infrastructure
with a CMS system overlaying measuring usage. Genesis have
request AMS metering to be post CMS to capture volumes for
billing and settlement.
Preventative actions taken to ensure no further issues will occur Completion
date
Genesis has requested meters which will remove the need for 10/2018
DUML databases.
17CONCLUSION
Odyssey Energy (2009) Limited (Odyssey) manages the installation, maintenance and database
management of all SWDC lighting connections.
SWDC are installing a CMS system and metering this DUML load, therefore this will no longer require an
audit as a DUML load which is expected to be by the end of August.
The database contains a small number of ballast discrepancies. These are discussed in the report.
The audit found three non-compliance issues and makes no recommendations. The future risk rating of
six indicates that the next audit be completed in 24 months.
18PARTICIPANT RESPONSE
Genesis, POCO and SWDC met to discuss the options they have in regards to DUML. We believe the
option to meter strings has been accepted. The need for a database of record should be dismissed upon
the implantation of all LED lighting and metering connections. The proposed date of completion was July
2018. No amendments to this date have been received.
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